MESSAGE NO: 5230111 DATE: 08 18 1995
CATEGORY: CVD TYPE: ORD
REFERENCE: REFERENCE DATE:
CASES: C - 475 - 815 - -
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PERIOD COVERED: 08 09 1995 TO

LIQ SUSPENSION DATE:

TO: REGIONAL DIRECTORS, COMMERCIAL OPERATIONS
DISTRICT, AREA AND PORT DIRECTORS

FROM: DIRECTOR, TECHNICAL PROGRAMS

RE: NOTICE OF CVD ORDER: SMALL DIAMETER CIRCULAR SEAMLESS
CARBON AND ALLOY STEEL STANDARD, LINE AND PRESSURE
PIPE ("SEAMLESS PIPE") FROM ITALY (C-475-815)

1. ON AUGUST 09, 1995, THE DEPARTMENT OF COMMERCE PUBLISHED IN
THE FEDERAL REGISTER THE COUNTERVAILING DUTY ORDER ON SMALL
DIAMETER CIRCULAR SEAMLESS CARBON AND ALLOY STEEL STANDARD, LINE
AND PRESSURE PIPE FROM ITALY.

2. THE PRODUCTS COVERED BY THIS INVESTIGATION AND ORDER INCLUDE
SMALL DIAMETER SEAMLESS CARBON AND ALLOY STANDARD, LINE AND
PRESSURE PIPES (SEAMLESS PIPES) PRODUCED TO THE ASTM A-335, ASTM
A-106, ASTM A-53 AND API 5L SPECIFICATIONS AND MEETING THE
PHYSICAL PARAMETERS DESCRIBED BELOW, REGARDLESS OF APPLICATION.
THE SCOPE OF THIS INVESTIGATION AND ORDER ALSO INCLUDES ALL
PRODUCTS USED IN STANDARD, LINE OR PRESSURE PIPE APPLICATIONS AND
MEETING THE PHYSICAL PARAMETERS BELOW, REGARDLESS OF
SPECIFICATION.

FOR PURPOSES OF THIS INVESTIGATION, SEAMLESS PIPES ARE SEAMLESS
CARBON AND ALLOY (OTHER THAN STAINLESS) STEEL PIPES, OF CIRCULAR
CROSS-SECTION, NOT MORE THAN 114.3 MM (4.5 INCHES) IN OUTSIDE
DIAMETER, REGARDLESS OF WALL THICKNESS, MANUFACTURING PROCESS
(HOT-FINISHED OR COLD-DRAWN), END FINISH (PLAIN END, BEVELLED
END, UPSET END, THREADED, OR THREADED AND COUPLED), OR SURFACE
FINISH. THESE PIPES ARE COMMONLY KNOWN AS STANDARD PIPE, LINE
PIPE OR PRESSURE PIPE, DEPENDING UPON THE APPLICATION. THEY MAY
ALSO BE USED IN STRUCTURAL APPLICATIONS, PIPES PRODUCED IN
NON-STANDARD WALL THICKNESSES ARE COMMONLY REFERRED TO AS TUBES.

THE SEAMLESS PIPES SUBJECT TO THESE INVESTIGATIONS ARE CURRENTLY
CLASSIFIABLE UNDER SUBHEADINGS 7304.10.1020, 7304.10.5020,
7304.31.6050, 7304.39.0016, 7304.39.0020, 7304.39.0024,
7304.39.0028, 7304.39.0032, 7304.51.5005, 7304.51.5060,
7304.59.6000, 7304.59.8010, 7304.59.8015, 7304.59.8020, AND
7304.59.8025 OF THE HARMONIZED TARIFF SCHEDULE OF THE UNITED
STATES ("HTSUS").

THE FOLLOWING INFORMATION FURTHER DEFINES THE SCOPE OF THIS
INVESTIGATION, WHICH COVERS PIPES MEETING THE PHYSICAL PARAMETERS
DESCRIBED ABOVE.

SPECIFICATIONS, CHARACTERISTICS, AND USES: SEAMLESS PRESSURE
PIPES ARE INTENDED FOR THE CONVEYANCE OF WATER, STEAM,
PETROCHEMICALS, CHEMICALS, OIL PRODUCTS, NATURAL GAS AND OTHER
LIQUIDS AND GASSES IN INDUSTRIAL PIPING SYSTEMS. THEY MAY CARRY
THESE SUBSTANCES AT ELEVATED PRESSURES AND TEMPERATURES AND MAY
BE SUBJECT TO THE APPLICATION OF EXTERNAL HEAT. SEAMLESS CARBON
STEEL PRESSURE PIPE MEETING THE AMERICAN SOCIETY FOR TESTING AND
MATERIALS (ASTM) STANDARD A-106 MAY BE USED IN TEMPERATURES OF UP
TO 1000 DEGREES FAHRENHEIT, AT VARIOUS AMERICAN SOCIETY OF
MECHANICAL ENGINEERS (ASME) CODE STRESS LEVELS. ALLOY PIPES MADE
TO ASTM STANDARD A-335 MUST BE USED IF TEMPERATURES AND STRESS
LEVELS EXCEED THOSE ALLOWED FOR A-106 AND THE ASME CODES.
SEAMLESS PRESSURE PIPES SOLD IN THE UNITED STATES ARE COMMONLY
PRODUCED TO THE ASTM A-106 STANDARD.

SEAMLESS STANDARD PIPES ARE MOST COMMONLY PRODUCED TO THE ASTM
A-53 SPECIFICATION AND GENERALLY ARE NOT INTENDED FOR HIGH
TEMPERATURE SERVICE. THEY ARE INTENDED FOR THE LOW TEMPERATURE
AND PRESSURE CONVEYANCE OF WATER, STEAM, NATURAL GAS, AIR AND
OTHER LIQUIDS AND GASSES IN PLUMBING AND HEATING SYSTEMS, AIR
CONDITIONING UNITS, AUTOMATIC SPRINKLER SYSTEMS, AND OTHER
RELATED USES. STANDARD PIPES (DEPENDING ON TYPE AND CODE) MAY
CARRY LIQUIDS AT ELEVATED TEMPERATURES BUT MUST NOT EXCEED
RELEVANT ASME CODE REQUIREMENTS.

SEAMLESS LINE PIPES ARE INTENDED FOR THE CONVEYANCE OF OIL AND
NATURAL GAS OR OTHER FLUIDS IN PIPE LINES. SEAMLESS LINE PIPES
ARE PRODUCED TO THE API 5L SPECIFICATION.

SEAMLESS PIPES ARE COMMONLY PRODUCED AND CERTIFIED TO MEET ASTM
A-106, ASTM A-53, AND API 5L SPECIFICATIONS. SUCH TRIPLE
CERTIFICATIONS OF PIPES IS COMMON BECAUSE ALL PIPES MEETING THE
STRINGENT A-106 SPECIFICATION NECESSARILY MEET THE API 5L AND
ASTM A-53 SPECIFICATIONS. PIPES MEETING THE API 5L SPECIFICATION
NECESSARILY MEET THE ASTM A-53 SPECIFICATION. HOWEVER, PIPES
MEETING THE A-53 OR API 5L SPECIFICATIONS DO NOT NECESSARILY MEET
THE A-106 SPECIFICATION. TO AVOID MAINTAINING SEPARATE
PRODUCTION RUNS AND SEPARATE INVENTORIES, MANUFACTURERS TRIPLE
CERTIFY THE PIPES. SINCE DISTRIBUTORS SELL THE VAST MAJORITY OF
THIS PRODUCT, THEY CAN THEREBY MAINTAIN A SINGLE INVENTORY TO
SERVICE ALL CUSTOMERS.

THE PRIMARY APPLICATION OF ASTM A-106 PRESSURE PIPES AND TRIPLE
CERTIFIED PIPES IS IN PRESSURE PIPING SYSTEMS BY REFINERIES,
PETROCHEMICAL PLANTS, AND CHEMICAL PLANTS. OTHER APPLICATIONS
ARE IN POWER GENERATION PLANTS (ELECTRICAL-FOSSIL FUEL OR
NUCLEAR), AND IN SOME OIL FIELD USES (ON SHORE AND OFF SHORE)
SUCH AS FOR SEPARATOR LINES, GATHERING LINES, AND METERING RUNS.
A MINOR APPLICATION OF THIS PRODUCT IS FOR USE AS OIL AND GAS
DISTRIBUTION LINES FOR COMMERCIAL APPLICATIONS. THESE
APPLICATIONS CONSTITUTE THE MAJORITY OF THE MARKET FOR THE
SUBJECT SEAMLESS PIPES. HOWEVER, A-106 PIPES MAY BE USED IN SOME
BOILER APPLICATIONS.

THE SCOPE OF THIS INVESTIGATION INCLUDES ALL SEAMLESS PIPE
MEETING THE PHYSICAL PARAMETERS DESCRIBED ABOVE AND PRODUCED TO
ONE OF THE SPECIFICATIONS LISTED ABOVE, REGARDLESS OF
APPLICATION, AND WHETHER OR NOT ALSO CERTIFIED TO A NON-COVERED
SPECIFICATION. STANDARD, LINE AND PRESSURE APPLICATIONS AND THE
ABOVE-LISTED SPECIFICATIONS ARE DEFINING CHARACTERISTICS OF THE
SCOPE OF THIS INVESTIGATION. THEREFORE, SEAMLESS PIPES MEETING
THE PHYSICAL DESCRIPTION ABOVE, BUT NOT PRODUCED TO THE A-335,
A-106, A-53, OR API 5L STANDARDS SHALL BE COVERED IF USED IN A
STANDARD, LINE OR PRESSURE APPLICATION.

FOR EXAMPLE, THERE ARE CERTAIN OTHER ASTM SPECIFICATIONS OF PIPE
WHICH, BECAUSE OF OVERLAPPING CHARACTERISTCS, COULD POTENTIALLY
BE USED IN A-106 APPLICATIONS. THESE SPECIFICATIONS GENERALLY
INCLUDE A-162, A-192, A-210, A-333, AND A-524. WHEN SUCH PIPES
ARE USED IN A STANDARD, LINE OR PRESSURE PIPE APPLICATION, SUCH
PRODUCTS ARE COVERED BY THE SCOPE OF THIS INVESTIGATION.

SPECIFICALLY EXCLUDED FROM THIS INVESTIGATION ARE BOILER TUBING
AND MECHANICAL TUBING, IF SUCH PRODUCTS ARE NOT PRODUCED TO
A-335, A-106, A-53 OR API 5L SPECIFICATIONS AND ARE NOT USED IN
STANDARD, LINE OR PRESSURE APPLICATIONS. IN ADDITION, FINISHED
AND UNFINISHED OCTG ARE EXCLUDED FROM THE SCOPE OF THIS
INVESTIGATION, IF COVERED BY THE SCOPE OF ANOTHER COUNTERVAILING
DUTY ORDER FROM THE SAME COUNTRY. IF NOT COVERED BY SUCH AN OCTG
ORDER, FINISHED AND UNFINISHED OCTG ARE INCLUDED IN THIS SCOPE
WHEN USED IN STANDARD, LINE OR PRESSURE APPLICATIONS. FINALLY,
ALSO EXCLUDED FROM THIS INVESTIGATION ARE REDRAW HOLLOWS FOR
COLD-DRAWING WHEN USED IN THE PRODUCTION OF COLD-DRAWN PIPE OR
TUBE.

ALTHOUGH THE HTSUS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND
CUSTOMS PURPOSES, OUR WRITTEN DESCRIPTION OF THE SCOPE OF THIS
INVESTIGATION IS DISPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES, THIS CASE HAS BEEN ASSIGNED
THE FOLLOWING CASE NUMBER C475-815.

4. FOR IMPORTS OF SEAMLESS PIPE FROM ITALY, THE CUSTOMS SERVICE
SHALL CONTINUE SUSPENSION OF LIQUIDATION OF SUCH SHIPMENTS THAT
ARE ENTERED OR WITHDRAWN FROM WAREHOUSE, FOR CONSUMPTION ON OR
AFTER NOVEMBER 28, 1994 AND BEFORE MARCH 28, 1995. ENTRIES OF
SEAMLESS PIPE MADE ON OR AFTER MARCH 28, 1995 AND PRIOR TO AUGUST
9, 1995 ARE NOT LIABLE FOR ASSESSMENT OF COUNTERVAILING DUTIES.

EFFECTIVE AUGUST 9, 1995, CUSTOMS SHALL REINSTATE SUSPENSION OF
LIQUIDATION OF SUCH SHIPMENTS THAT ARE ENTERED OR WITHDRAWN FROM
WAREHOUSE FOR CONSUMPTION AND REQUIRE A CASH DEPOSIT FOR SUCH
ENTRIES EQUAL TO THE SUBSIDY RATE SHOWN BELOW:

MANUFACTURERS/PRODUCERS/ CUSTOMS ID MARGIN/
EXPORTERS NUMBER PERCENT

COUNTRY WIDE C-475-815-000 1.47%

THIS SUSPENSION SHALL REMAIN IN EFFECT UNTIL FURTHER NOTICE.

5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT VIA EMAIL, THROUGH THE APPROPRIATE
SUPERVISORY CHANNELS, TECHNICAL PROGRAMS,
ANTIDUMPING/COUNTERVAILING DUTY USING ATTRIBUTE "HQ OAB".THE
IMPORTING PUBLIC AND OTHER INTERESTED PARTIES SHOULD CONTACT
PETER WILKNISS, OFFICE OF COUNTERVAILING INVESTIGATIONS, IMPORT
ADMINISTRATION, INTERNATIONAL TRADE ADMINISTRATION, U.S.
DEPARTMENT OF COMMERCE, TELEPHONE (202) 482-0588.

6. THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS INFORMATION.

NANCY MCTIERNAN